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If the employer has a release that does cause substantial property damage, does reporting to the National Response Center (NRC) meet the reporting requirement to the Chemical Safety Board (CSB)?
Technical enforcement and assistance guidelines for hazardous waste site and RCRA corrective action clean-up operations [11 02 2003]
Appendix B to Part 118—Toxicity Endpoints for Calculating Planning Distance for Fish, Wildlife and Sensitive Environments and Public Receptors
84 FR 66369 EPA: Addition of Certain Per- and Polyfluoroalkyl Substances; Community Right-to-Know Toxic Chemical Release Reporting